By David Bucciferro, chair, EHR Association.
The EHR Association has long supported the goals of the Health Data, Technology, and Interoperability: Certification Program Updates, Algorithm Transparency, and Information Sharing Proposed Rule (HTI-1) released in April by the Office of the National Coordinator for Health Information Technology (ONC). However, we have real concerns about the impact it would have on the industry if finalized as proposed.
Many center on the proposed implementation timeframes associated with various concepts included in HTI-1, as well as ONC’s failure to sufficiently consider the burden compliance will place on provider organizations and health IT developers. Specifically, health IT developers need more time than allotted in HTI-1 to deliver safe, compliant, and high-quality versions of their certified products. Providers will also need sufficient time to implement and become proficient with that upgraded software.
We also encourage ONC and the Centers for Medicare and Medicaid Services (CMS) to work more closely together to address the misalignments that frequently occur between when ONC tells software developers to deploy new certified versions and when CMS requires providers to be using them. There are also proposals in HTI-1 that create a dependency on collaboration with healthcare provider organizations for developers to be successful in meeting their obligations, but CMS has included in rulemaking no corresponding incentives for them to do so – making compliance for vendors significantly more challenging.
We have also identified issues with four specific provisions of HTI-1: Insights Condition, USCDI v3, Decision Support Interventions (DSI) and Predictive Models, and Patient Requested Restrictions.